Taxation (International and Other Provisions) Act 2010 section 259F

Overview of Chapter

Section 259F provides an overview of the chapter dealing with excessive tax deductions that arise when a multinational company's UK permanent establishment makes transfers of money or assets to the company in its home jurisdiction.

• The chapter targets excessive tax deductions arising from transfers between a UK permanent establishment and its parent company abroad
• Counteraction is achieved by adjusting the corporation tax treatment of the multinational company in the UK
• Section 259FA sets out the conditions that must be met, including definitions of "multinational company", "the parent jurisdiction", and "the excessive PE deduction"
• Section 259FB provides the mechanism for counteracting the excessive permanent establishment deduction

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